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`Case 2:22-cv-01009 Document 1 Filed 07/21/22 Page 1 of 62
`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF WASHINGTON
`SEATTLE DIVISION
`
`SECURITIES AND EXCHANGE COMMISSION,
`
` Plaintiff,
`
` v.
`
`ISHAN WAHI, NIKHIL WAHI, AND SAMEER
`RAMANI,
`
` Defendants.
`
`
`
`
` Civil Action No. _________
`
`COMPLAINT
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`
`
`Plaintiff United States Securities and Exchange Commission (the “Commission”), for its
`
`Complaint against Defendants Ishan Wahi, Nikhil Wahi, and Sameer Ramani, alleges as follows:
`
`SUMMARY
`
`1.
`
`This case involves insider trading in certain crypto asset securities that Coinbase
`
`Global, Inc. (“Coinbase”) announced would be “listed,” or made available to trade, on its crypto
`
`asset trading platform. From at least June 2021 through April 2022, Ishan Wahi (“Ishan”), a
`
`manager in Coinbase’s Assets and Investing Products group, repeatedly tipped material, nonpublic
`
`information about the timing and content of Coinbase’s “listing announcements” – in which
`
`Coinbase announced that crypto assets would be listed on its trading platform – to his brother Nikhil
`
`Wahi (“Nikhil”) as well as his close friend Sameer Ramani (“Ramani”). Nikhil and Ramani used
`
`this information to trade ahead of multiple listing announcements, earning at least $1.1 million in
`
`illicit profits.
`
`2.
`
`Ishan violated the duty of trust and confidence he owed to Coinbase when he
`
`repeatedly tipped Nikhil and Ramani. In turn, Nikhil and Ramani each repeatedly traded on the
`
`Complaint
`SEC v. Wahi, et al.
`Case No.
`
`
`- 1 -
`
`Securities and Exchange Commission
`100 F Street NE
`Washington, DC 20549
`Telephone: (202) 551-4737
`
`

`

`Case 2:22-cv-01009 Document 1 Filed 07/21/22 Page 2 of 62
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`basis of material, nonpublic information that they knew, were reckless in not knowing, or
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`consciously avoided knowing that Ishan had provided them in breach of his duty to Coinbase and
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`for a personal benefit. Ishan benefitted from his tip because he bestowed gifts of valuable material,
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`nonpublic information on a trading relative and a close friend.
`
`3.
`
`Coinbase is one of the largest crypto asset trading platforms in the U.S., with more
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`than 98 million registered users. Coinbase has had a practice, since at least May 2020, of publicly
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`announcing on its blog or Twitter feed when it will begin listing certain crypto assets on its trading
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`platform. The prices of crypto assets identified in these listing announcements, including crypto
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`asset securities, typically appreciate quickly and significantly. (As used in this complaint, “crypto
`
`asset security” refers to an asset that is issued and/or transferred using distributed ledger or
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`blockchain technology – including, but not limited to, so-called “digital assets,” “virtual
`
`currencies,” “coins,” and “tokens” – and that meets the definition of “security” under the federal
`
`securities laws.) The trading volume also multiplies, sometimes exponentially.
`
`4.
`
`At all relevant times, Coinbase’s employee policies stated that “material nonpublic
`
`information” included “information about a decision by Coinbase to list, not list, or add features to a
`
`Digital Asset [separately defined to include tokens].” The policies further emphasized that
`
`Coinbase employees should never disclose material, nonpublic information to any other person,
`
`including family and friends, or tip others who might make a trading decision using that material,
`
`nonpublic information.
`
`5.
`
`As a manager in Coinbase’s Assets and Investing Products group, Ishan – who had
`
`expressly acknowledged his duty to keep listings information confidential – was entrusted with
`
`first-hand knowledge of what crypto assets Coinbase planned to support and when Coinbase
`
`planned to make listing announcements. He also knew that conversations about this confidential
`
`Complaint
`SEC v. Wahi, et al.
`Case No.
`
`
`- 2 -
`
`Securities and Exchange Commission
`100 F Street NE
`Washington, DC 20549
`Telephone: (202) 551-4737
`
`

`

`Case 2:22-cv-01009 Document 1 Filed 07/21/22 Page 3 of 62
`
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`information needed to be limited, even within Coinbase, to – as Ishan himself once noted – a
`
`“tighter circle.”
`
`6.
`
`Nevertheless, ahead of multiple listing announcements in 2021 and 2022, and in
`
`breach of the duty he owed to Coinbase, Ishan repeatedly tipped his brother, Nikhil, and his close
`
`friend, Ramani, with material, nonpublic information about those listings’ timing and content.
`
`Ishan communicated by phone and text with both Nikhil and Ramani during 2021 and 2022,
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`including exchanging phone calls and messages with both that would not be captured in U.S. phone
`
`company records because, among other things, Ishan was using a phone with a non-U.S. phone
`
`number (the “Foreign Phone”). For example, on October 20, 2021, the same day as a Coinbase
`
`listing announcement, Nikhil messaged Ishan’s Foreign Phone a dollar sign and the eyes emoji: “$
`👀👀.”
`
`7.
`
`Nikhil and Ramani, who knew, consciously avoided knowing, or were reckless in not
`
`knowing that Ishan was breaching a duty by providing them with this listing information, repeatedly
`
`purchased the crypto assets Coinbase planned to list ahead of these announcements. Between at
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`least June 2021 and April 2022, blockchain addresses linked to Nikhil and Ramani traded ahead of
`
`– sometimes just minutes before – more than 10 such announcements, trading in at least 25 crypto
`
`assets. As alleged in this Complaint, this repeated pattern of Ishan tipping Nikhil and Ramani with
`
`inside information, followed by Nikhil and Ramani trading on that information, included trading in
`
`at least nine crypto asset securities, which were listed in seven of these announcements.
`
`8.
`
`For example, on November 12, 2021, Ishan learned that Coinbase would soon
`
`announce the listing of the crypto asset POWR. As alleged further below, POWR was a crypto
`
`asset security. On November 15, 2021, just minutes after receiving confirmation that POWR would
`
`be listed later that day, Ishan called Nikhil. Beginning at 2:52 pm ET – just two minutes before the
`
`Complaint
`SEC v. Wahi, et al.
`Case No.
`
`
`- 3 -
`
`Securities and Exchange Commission
`100 F Street NE
`Washington, DC 20549
`Telephone: (202) 551-4737
`
`

`

`Case 2:22-cv-01009 Document 1 Filed 07/21/22 Page 4 of 62
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`Coinbase listing announcement – a blockchain address Nikhil controlled purchased 18,413 POWR
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`at a cost of approximately $7,000. Almost immediately after the announcement, that blockchain
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`address exchanged those POWR tokens for approximately $10,050 in another crypto asset. As a
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`result, Nikhil realized illicit proceeds of approximately $3,050.
`
`9.
`
`Nikhil’s and Ramani’s suspicious trading drew attention. On May 11, 2022,
`
`Coinbase’s Director of Security Operations emailed Ishan to schedule an interview with Coinbase’s
`
`Legal Department in connection with an “ongoing company investigation into Coinbase’s asset
`
`listing process.” Ishan – using the Foreign Phone – then sent a screen shot of the interview request
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`to both Nikhil and Ramani, and stated that he needed to speak with them urgently. On Monday,
`
`May 16 – the day of his scheduled interview – Ishan emailed coworkers that he would be “out
`
`indefinitely” because he “had to fly back to India overnight.” Ishan did not appear for his scheduled
`
`interview, but was prevented from leaving the country by law enforcement. Using the Foreign
`
`Phone, Ishan tried to call both Nikhil and Ramani several times on May 16.
`
`NATURE OF PROCEEDING AND RELIEF SOUGHT
`
`10.
`
`The Commission brings this action against Ishan Wahi, Nikhil Wahi, and Ramani
`
`pursuant to Sections 21(d), 21A, and 27 of the Securities Exchange Act of 1934, 15 U.S.C. §§ 78u,
`
`78u-l, and 78aa (“Exchange Act”) to enjoin the transactions, acts, practices, and courses of business
`
`alleged in this Complaint and to seek disgorgement, prejudgment interest, civil penalties, and such
`
`further relief that the Court may deem appropriate.
`
`JURISDICTION AND VENUE
`
`11.
`
`The federal securities laws define what a security is. That definition includes
`
`“investment contracts.” Section 2(a)(1) of the Securities Act of 1933, 15 U.S.C. § 77b(a)(1);
`
`Section 3(a)(10) of the Exchange Act, 15 U.S.C. § 78c(a)(10); see also SEC v. W.J. Howey Co., 328
`
`Complaint
`SEC v. Wahi, et al.
`Case No.
`
`
`- 4 -
`
`Securities and Exchange Commission
`100 F Street NE
`Washington, DC 20549
`Telephone: (202) 551-4737
`
`

`

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`Case 2:22-cv-01009 Document 1 Filed 07/21/22 Page 5 of 62
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`
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`U.S. 293, 298-99 (1946) (interpreting “investment contract”). The law vests the Commission with
`
`broad jurisdiction to regulate the securities markets and to bring actions for violations of the federal
`
`securities laws, including fraud and insider trading. See Sections 10(b), 21, 21A, and 27 of the
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`Exchange Act, 15 U.S.C. §§ 78j(b), 78u, 78u-1, and 78aa; see also Commodity Exchange Act
`
`Sections 1(a)(41) and 2(a)(1)(A), 7 U.S.C. §§ 1(a)(41), 2(a)(1)(A) (preserving the SEC’s
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`jurisdiction and confirming that the federal securities laws apply to securities).
`
`12.
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`This Court has jurisdiction over this action pursuant to Sections 21(d), 21(e), 21A,
`
`and 27 of the Exchange Act, 15 U.S.C. §§ 78u(d), 78u(e), 78u-1, and 78aa.
`
`13.
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`Venue in this district is proper pursuant to Section 27(a) of the Exchange Act, 15
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`U.S.C. §§ 78aa(a). Certain of the purchases and sales of securities and acts, practices, transactions,
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`and courses of business constituting the violations alleged in this Complaint occurred within the
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`Western District of Washington, and were effected, directly or indirectly, by making use of the
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`means, instruments, or instrumentalities of transportation or communication in interstate commerce.
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`In particular, many of the communications and trades described herein originated in, or were
`
`ordered from, this District. Moreover, during the relevant period, Defendants Ishan and Nikhil
`
`resided in this District.
`
`Complaint
`SEC v. Wahi, et al.
`Case No.
`
`
`- 5 -
`
`Securities and Exchange Commission
`100 F Street NE
`Washington, DC 20549
`Telephone: (202) 551-4737
`
`

`

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`Case 2:22-cv-01009 Document 1 Filed 07/21/22 Page 6 of 62
`
`
`
`DEFENDANTS
`
`14.
`
`Ishan Wahi, 32, is a citizen of India, residing in Seattle, Washington on a work visa.
`
`From October 2020 to late May 2022, when he was placed on administrative leave, Ishan was a
`
`manager in Coinbase’s Assets and Investing Products group. In response to an SEC subpoena for
`
`documents, Ishan asserted his Fifth Amendment right against self-incrimination.
`
`15.
`
`Nikhil Wahi, 26, is a citizen of India, residing in Seattle, Washington. Nikhil is a
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`senior product manager at Salesforce, Inc., where he has been employed since 2017. Nikhil is
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`Ishan’s brother. Nikhil has refused to respond to an SEC subpoena for documents.
`
`16.
`
`Sameer Ramani, 33, is a resident of Houston, Texas, and a citizen of the U.S.
`
`Ramani is believed to currently be in India. Ramani and Ishan attended the University of Texas at
`
`Austin at the same time and remain close friends.
`
`RELEVANT ENTITY
`
`17.
`
`Coinbase Global, Inc., incorporated in Delaware and headquartered in San
`
`Francisco, California, operates one of the largest crypto asset trading platforms in the United States.
`
`Coinbase’s common stock is registered with the Commission under Section 12(b) of the Exchange
`
`Act, and its securities are traded publicly on the Nasdaq Stock Market under the ticker symbol
`
`COIN.
`
`FACTS
`
`Blockchains and Crypto Assets
`
`18.
`
`A blockchain is a type of distributed ledger or peer-to-peer database that is spread
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`across a network and keeps track of all transactions in the network in theoretically unchangeable,
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`digitally-recorded data packages called “blocks.” Each block contains a batch of records of
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`transactions, including a timestamp and a reference to the previous block, so that the blocks together
`
`Complaint
`SEC v. Wahi, et al.
`Case No.
`
`
`- 6 -
`
`Securities and Exchange Commission
`100 F Street NE
`Washington, DC 20549
`Telephone: (202) 551-4737
`
`

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`Case 2:22-cv-01009 Document 1 Filed 07/21/22 Page 7 of 62
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`
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`form a chain. A blockchain can be shared and accessed by anyone with appropriate permissions.
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`The Ethereum blockchain is a well-known blockchain.
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`19.
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`Crypto assets are unique digital assets maintained on a cryptographically-secured
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`blockchain. One type of crypto asset – the kind at issue in this case – is known as a “token.”
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`Enormous numbers of tokens can be created at once or over time. The blockchain records the
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`creation (or “minting”) of the tokens and then keeps track of the blockchain address that controls
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`the tokens.
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`20.
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`The crypto asset securities purchased and sold in the transactions at issue in this
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`matter were created using the “ERC-20” protocol on the Ethereum blockchain.
`
`Ownership of Crypto Assets
`
`21.
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`People own crypto assets, such as the crypto asset securities traded in the
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`transactions at issue in this matter, and hold them within a blockchain address under their control.
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`Often, someone controls an address—and the crypto assets held therein—through holding a private
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`key for that address. Anyone with that private key can submit a transaction to the blockchain that
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`will transfer the crypto assets at that address to another address. In a single blockchain address,
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`people can hold multiple types of crypto assets.
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`22.
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`People often control multiple blockchain addresses. They often store their private
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`keys for those addresses in software called a “wallet” that allows them to submit transactions using
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`the software rather than directly sending orders to a blockchain.
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`23.
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`People can also own crypto assets by opening an account with Coinbase or other
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`crypto asset trading platforms, sometimes also referred to herein as secondary trading platforms,
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`and then transferring their crypto assets from their personal blockchain address to an address
`
`Complaint
`SEC v. Wahi, et al.
`Case No.
`
`
`- 7 -
`
`Securities and Exchange Commission
`100 F Street NE
`Washington, DC 20549
`Telephone: (202) 551-4737
`
`

`

`Case 2:22-cv-01009 Document 1 Filed 07/21/22 Page 8 of 62
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`controlled by the trading platform. In a secondary trading platform account, people can hold
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`multiple types of crypto assets, along with currency such as U.S. dollars or Euros.
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`Crypto Asset Securities
`
`24.
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`A digital token or crypto asset is a crypto asset security if it meets the definition of a
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`security, which the Securities Act defines to include “investment contract,” i.e., if it constitutes an
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`investment of money, in a common enterprise, with a reasonable expectation of profit derived from
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`the efforts of others. As described in greater detail below, during the relevant period, Ishan
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`provided material, nonpublic information about, and Nikhil and Ramani traded in, at least nine
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`crypto asset securities that meet this definition.
`
`25.
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`After the initial sale by the issuer, crypto assets are often traded on secondary trading
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`platforms, such as Coinbase. Crypto asset issuers may apply to these trading platforms to have
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`crypto assets listed and made available for trading; the trading platforms select what crypto assets
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`may be bought and sold on their systems. The existence of the secondary trading market offered by
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`platforms such as Coinbase allows market participants to buy and sell crypto assets, including
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`crypto asset securities. Secondary market trading in crypto assets has grown exponentially, and the
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`announcement of the listing of a crypto asset, including a crypto asset security, on Coinbase
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`typically causes that asset’s price and trading volume to rise dramatically.
`
`Ishan Was Entrusted With Material, Nonpublic Information and Had a Duty to Keep That
`Information Confidential and Not Disclose It to Other Persons
`
` In October 2020, Coinbase hired Ishan as a manager in its Assets and Investing
`
`26.
`
`Products group, which was responsible for supporting and coordinating the Coinbase listing
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`announcements described herein. Coinbase determined that because Ishan was regularly entrusted
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`with material, nonpublic information, he was a “Covered Person” under its Global Trading Policy
`
`and Digital Asset Trading Policy (the “Policies”).
`- 8 -
`
`Complaint
`SEC v. Wahi, et al.
`Case No.
`
`
`Securities and Exchange Commission
`100 F Street NE
`Washington, DC 20549
`Telephone: (202) 551-4737
`
`

`

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`Case 2:22-cv-01009 Document 1 Filed 07/21/22 Page 9 of 62
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`27.
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`During the relevant period, the Policies stated that “You may disclose Material
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`Nonpublic Information ONLY to Personnel designated by your manager. You should never
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`disclose Material Nonpublic Information to any other person, even co-workers, family or friends.”
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`The Policies expressly defined “material nonpublic information” to include “information about a
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`decision by Coinbase to list, not list, or add features to a Digital Asset [separately defined to include
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`tokens].” The Policies specifically emphasized that Coinbase employees should not disclose
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`material, nonpublic information, and included examples of activities that were “Not OK,” including
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`trading in advance of the listing of new digital assets on its trading platform:
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`Coinbase publicly announces that it will support a new digital asset in
`the coming year. You are an engineer that is helping to implement support of
`the new asset and you know that Coinbase plans a surprise early launch next
`week, so you buy the token.
`
`You are involved with a fund which invests in digital assets. You are
`involved in deciding when the fund buys and sells digital assets, and you
`advise the fund to buy a particular asset because you know Coinbase is going
`to start trading the asset.
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`You buy a digital asset which you know is or may be part of Coinbase’s non-public
`product roadmap or launch plans.
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`On or around the day he joined Coinbase, Ishan signed an acknowledgement that he
`
`28.
`
`had read and understood the Policies.
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`29.
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`By virtue of his position as a Product Manager in Coinbase’s Assets and Investing
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`Products group, Ishan was directly involved in the asset listing process. He had first-hand
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`knowledge of what crypto assets Coinbase planned to list and when Coinbase planned to announce
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`an asset listing.
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`30.
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`Ishan also understood the need to keep this information confidential, and that access
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`to it was restricted even within Coinbase. In August 2021, Coinbase’s Assets and Investing
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`Products group created an internal Slack channel, of which Ishan was an original participant, as “a
`- 9 -
`
`Complaint
`SEC v. Wahi, et al.
`Case No.
`
`
`Securities and Exchange Commission
`100 F Street NE
`Washington, DC 20549
`Telephone: (202) 551-4737
`
`

`

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`Case 2:22-cv-01009 Document 1 Filed 07/21/22 Page 10 of 62
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`safe place to discuss details around asset launches that we are trying not to share anymore in the
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`broader listings channels (e.g., exact announcement / launch dates + timelines).” In an August 19,
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`2021 message to the group, which included Ishan, an employee suggested changing the asset listing
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`process so that fewer employees would have advance knowledge “[a]s we are trying to protect
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`MNPI [material nonpublic information].” In a February 2, 2022 message, Ishan’s colleague
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`reminded the Assets and Investing Products group that anyone on the Slack channel “must be on the
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`Enhanced Trading Policy (Covered Persons) as the information discussed here is MNPI.”
`
`31.
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`Ishan recognized the importance of keeping listings information confidential, later
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`instructing everyone: “Please do not add anyone else to this channel.” Indeed, when asked if
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`engineers could be added to the Slack channel, Ishan suggested keeping the Asset Listing Group’s
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`channel limited to “a tighter circle.”
`
`Ishan Had a Close Relationship with Nikhil and Ramani and Communicated With Them
`Frequently Throughout the Relevant Period
`
`Ishan and Nikhil have a close relationship. For example, between June 2021 and
`
`32.
`
`April 2022, they typically communicated by text and phone multiple times a day.
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`33.
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`The brothers also have a history of financial transactions with each other: for
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`example, on February 11, 2021, Nikhil deposited a $20,000 check from Ishan, purportedly a “loan”;
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`on March 1, 2021, Nikhil transferred $2,000 to Ishan. On April 17, 2022, Nikhil transferred crypto
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`assets valued at $19,500 from his Coinbase account to Ishan’s Coinbase account.
`
`34.
`
`Ramani and Ishan have known each other since at least 2013. They attended the
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`University of Texas at Austin at the same time. They follow each other on social media, including
`
`Soundcloud. The friends exchanged phone calls and text messages in 2021 and 2022.
`
`35.
`
`At least by July 2021, Ishan possessed the Foreign Phone, a cell phone with a non-
`
`U.S. phone number. Ishan used the Foreign Phone to communicate with Nikhil and Ramani,
`- 10 -
`
`Complaint
`SEC v. Wahi, et al.
`Case No.
`
`
`Securities and Exchange Commission
`100 F Street NE
`Washington, DC 20549
`Telephone: (202) 551-4737
`
`

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`Case 2:22-cv-01009 Document 1 Filed 07/21/22 Page 11 of 62
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`particularly in April and May 2022. In his communications with Nikhil and Ramani using the
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`Foreign Phone, Ishan used communications methods that would not be logged by a U.S. phone
`
`company, including by using applications such as WhatsApp to communicate with his brother and
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`friend.
`
`Defendants Repeatedly Engaged in Insider Trading in Crypto Asset Securities in Advance of
`Coinbase Listing Announcements
`
`As set forth in more detail below, between at least June 2021 and April 2022, Ishan
`
`36.
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`repeatedly tipped Nikhil and Ramani with material, nonpublic information in advance of Coinbase’s
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`listing announcements of certain crypto asset securities.
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`37.
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`Nikhil and Ramani, who knew, consciously avoided knowing, or were reckless in not
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`knowing that Ishan was providing this material, nonpublic information in breach of his duty to
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`Coinbase and for a personal benefit, repeatedly traded using that information, reaping substantial
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`profits.
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`38.
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`Because all of the Defendants understood that Ishan was providing material,
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`nonpublic information in breach of his duty to Coinbase, the Defendants took steps to conceal their
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`communications and trading, including by utilizing multiple accounts, wallets, and addresses across
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`multiple platforms, including foreign trading platforms, in carrying out their trading in advance of
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`Coinbase’s listing announcements.
`
`Complaint
`SEC v. Wahi, et al.
`Case No.
`
`
`- 11 -
`
`Securities and Exchange Commission
`100 F Street NE
`Washington, DC 20549
`Telephone: (202) 551-4737
`
`

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`Case 2:22-cv-01009 Document 1 Filed 07/21/22 Page 12 of 62
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`
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`A. The June 8, 2021 Listing Announcement – AMP
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`By virtue of his position at Coinbase, on or before June 6, 2021, Ishan learned that
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`39.
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`Coinbase planned to announce the listing of crypto asset AMP on its platform. As alleged further
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`below, AMP was a crypto asset security.
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`40.
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`On June 7, 2021, a blockchain address that has directly or indirectly sent funds to,
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`and received funds from, Ramani (the “Ramani AMP Trading Address A”) bought nearly 700,000
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`AMP tokens at a cost of approximately $30,650.
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`41.
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`On the morning of June 8, 2021, a second address (the “Ramani AMP Trading
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`Address B”), which, directly or indirectly, has sent funds to Ramani, purchased approximately
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`1,165,000 AMP tokens, at a cost of approximately $49,000.
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`42.
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`On June 8, 2021, at 1:00 pm ET, Coinbase announced that it was listing AMP.
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`AMP’s price quickly rose more than 11%, while its trading volume more than tripled.
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`43.
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`On June 10 and June 11, 2021, the two Ramani AMP Trading Addresses sold nearly
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`all of the AMP tokens they had purchased for Ethereum tokens (“ETH,” a widely used
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`cryptocurrency) valued at approximately $97,600, representing profits of approximately $17,950.
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`44.
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`Ramani AMP Trading Addresses A and B then transferred the ETH to a deposit
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`blockchain address held by Ramani at a foreign trading platform on June 10 and 11, 2021.
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`B. The July 14, 2021 Listing Announcement – RLY
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`By virtue of his position at Coinbase, on or around July 12, 2021, Ishan learned that
`
`45.
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`Coinbase intended to announce on July 14 that the RLY token would be listed on its platform. As
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`alleged further below, RLY was a crypto asset security. The next day, on July 13, 2021, Ishan and
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`Nikhil called each other several times.
`
`Complaint
`SEC v. Wahi, et al.
`Case No.
`
`
`- 12 -
`
`Securities and Exchange Commission
`100 F Street NE
`Washington, DC 20549
`Telephone: (202) 551-4737
`
`

`

`Case 2:22-cv-01009 Document 1 Filed 07/21/22 Page 13 of 62
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`46.
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`On July 13, 2021, at 4:45 am ET, a blockchain address that has received funds from
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`Nikhil (the “Nikhil RLY Trading Address”), funneled through two intermediary addresses in a
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`series of transactions, began trading in RLY tokens. Before Coinbase’s RLY listing announcement
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`the next day, the Nikhil RLY Trading Address had a net accumulation of approximately 34,000
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`tokens, at a cost of approximately $14,500.
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`47.
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`On July 14, 2021, Coinbase announced RLY’s listing. As the day progressed,
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`RLY’s price rose approximately 20%, while its trading volume increased by nearly 60%.
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`48.
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`Over the next two days, the Nikhil RLY Trading Address sold the approximately
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`34,000 RLY tokens for approximately $16,200, earning an approximate profit of $1,700.
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`49.
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`On July 19, 2021, the RLY Trading Address transferred the equivalent of
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`approximately $34,750 to a deposit address at a foreign trading platform that was controlled by
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`Nikhil using a pseudonymous email address.
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`C. The August 31, 2021 Listing Announcement -- DDX
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`On August 19, 2021, participants in a private Coinbase Slack channel for “@asset-
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`50.
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`listings” – a group that included Ishan – discussed Coinbase’s plan to list crypto asset DDX, among
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`others, on August 24, 2021. Another participant in that discussion proposed changes to pre-listing
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`activities because “we are trying to protect MNPI [material nonpublic information].” As alleged
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`further below, DDX was a crypto asset security.
`
`51.
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`Coinbase initially slated the announcement of DDX’s listing for August 24, 2021,
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`but then rescheduled it to August 31, 2021.
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`52.
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`On August 25, 2021, a blockchain address that had sent funds, directly or indirectly,
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`to Ramani (the “Ramani DDX Trading Address A”) began trading in DDX tokens, accumulating a
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`total of approximately 3,450 tokens by August 29, for a cost of approximately $18,700.
`
`Complaint
`SEC v. Wahi, et al.
`Case No.
`
`
`- 13 -
`
`Securities and Exchange Commission
`100 F Street NE
`Washington, DC 20549
`Telephone: (202) 551-4737
`
`

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`Case 2:22-cv-01009 Document 1 Filed 07/21/22 Page 14 of 62
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`53.
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`On August 31, 2021, a second address that has also previously sent funds, directly or
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`indirectly, to Ramani (the “Ramani DDX Trading Address B”) purchased approximately 3,670
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`DDX tokens at a cost of approximately $30,000 in 10 separate transactions between 8:20 am ET
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`and 12:58 pm ET.
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`54.
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`Approximately two hours later, Coinbase announced that DDX would be made
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`available for trading. Following the announcement, the market price for DDX spiked
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`approximately 145% in a little more than an hour, while trading volume increased over 470% from
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`the previous day’s trading.
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`55.
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`Later in the day on August 31, 2021, the Ramani DDX Trading Addresses A and B
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`sold their DDX in exchange for another crypto asset, for a combined profit of approximately
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`$37,000.
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`56.
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`On September 1, 2021, the Ramani DDX Addresses A and B sent the equivalent of
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`approximately $102,384 to the same deposit address on a foreign trading platform. This deposit
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`address has, directly or indirectly, sent funds to Ramani.
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`D. The September 8, 2021 Listing Announcement – XYO and RGT
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`On August 30, 2021, participants in the private Coinbase Slack channel “@asset-
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`57.
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`listings” – a group that included Ishan – discussed “tomorrow’s announcement” that Coinbase
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`planned to list the XYO and RGT tokens. As set forth further below, XYO and RGT were both
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`crypto asset securities.
`
`Complaint
`SEC v. Wahi, et al.
`Case No.
`
`
`- 14 -
`
`Securities and Exchange Commission
`100 F Street NE
`Washington, DC 20549
`Telephone: (202) 551-4737
`
`

`

`Case 2:22-cv-01009 Document 1 Filed 07/21/22 Page 15 of 62
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`(1) Ramani’s Trading in XYO
`
`58.
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`On August 31, eight blockchain addresses, each of which has sent funds, directly or
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`indirectly, to Ramani, began buying XYO.
`
`59.
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`Later on the afternoon of August 31, a manager in Coinbase’s Assets and Investing
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`Products group informed the group, including Ishan, that Coinbase would not announce its planned
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`listing of RGT and XYO on August 31. Instead, the listing “will be pushed out to next week.” On
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`September 1, though, at 10:44 am ET, there was another discussion on the @asset-listing Slack
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`channel about announcing the listing of XYO later that day. Shortly thereafter, at 11:21 am ET, a
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`blockchain address that, directly or indirectly, has sent funds to Ramani began buying XYO. The
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`XYO listing announcement was later pushed again, to September 8.
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`60.
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`Between September 1 and 8, 2021, an additional six blockchain addresses, each of
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`which, directly or indirectly, has sent funds to or received funds from Ramani, bought XYO. In
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`total, 15 blockchain addresses linked to Ramani (the “Ramani XYO Buying Addresses”) bought
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`approximately 38 million XYO tokens, valued at $600,000, before Coinbase announced, on
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`September 8, 2021, that it would list XYO and RGT.
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`61. Within minutes of the listing announcement, the price of XYO increased more than
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`20%, while trading volume increased 263% the day of the announcement, and then more than
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`quadrupled again the next trading day.
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`62.
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`Between September 8 and 12, 2021, each of the 15 Ramani XYO Buying Addresses
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`transferred their XYO tokens to the same address (the “Ramani XYO Selling Address”), which,
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`directly or indirectly, had also previously received funds from, and sent funds to, Ramani. Between
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`September 9 and 12, 2021, the Ramani XYO Selling Address transferred the approximately 38
`
`million XYO tokens to a blockchain address on a foreign trading platform.
`
`Complaint
`SEC v. Wahi, et al.
`Case No.
`
`
`- 15 -
`
`Securities and Exchange Commission
`100 F Street NE
`Washington, DC 20549
`Telephone: (202) 551-4737
`
`

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`Case 2:22-cv-01009 Document 1 Filed 07/21/22 Page 16 of 62
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`63.
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`At the time of these transfers, Ramani’s XYO tokens were valued at approximately
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`$1.5 million, representing a profit of approximately $900,00